How Long Can Personal Data Be Kept for GDPR?
Let’s get straight to it: the GDPR doesn’t tell you a fixed number of days, months, or years to retain personal data. Instead, it tells you this — don’t keep it longer than necessary. Simple in theory. But in practice? A little more complex.
The GDPR retention period principle challenges organisations to think critically about why they collect data and how long it truly serves its purpose. In this post, we’ll unpack what that means, how to approach it strategically, and how to avoid the trap of “just in case” data hoarding.
What the GDPR Says About Data Retention
At the heart of GDPR is the principle of storage limitation, laid out in Article 5(1)(e). It requires that personal data be:
“Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.”
The “Necessary” Factor
The challenge? “Necessary” isn’t defined numerically. You, as the data controller, need to determine what’s appropriate based on the purpose for which the data is being processed.
Customer data for billing may need to be retained for 7 years to comply with tax laws.
Candidate CVs for rejected applicants might only need to be kept for 6 months.
Exceptions and Legal Obligations
The GDPR does allow longer retention if it’s for:
Legal obligations (e.g., accounting, employment laws)
Archiving in the public interest
Scientific or historical research
Statistical purposes
In these cases, proper safeguards (like pseudonymisation) must be in place.
Managing Retention Periods: A Strategic Challenge
For privacy professionals and compliance teams, defining, enforcing, and reviewing retention policies can be a headache. But it doesn’t have to be.
Define Clear Retention Schedules
Start by categorising your processing activities. A well-documented Record of Processing Activities (ROPA) is your best friend here.
Map out the personal data types
Link each to its processing purpose
Define legal or business-based retention timelines
Explore our Privacy Management module to simplify your data mapping, DPIAs, TIAs and more.
Automate Reviews and Deletion
Setting a retention schedule is only step one. If data quietly sits beyond its expiry, you’re still non-compliant.
Use tools like automated triggers for review or deletion processes — think lifecycle workflows that archive or anonymise data after a set period.
For example, set automatic deletion of inactive user accounts after 24 months
Or prompt a data owner review every 6 months
Responsum’s Risk Management and Policies & Procedures modules make setting, monitoring, and proving these actions a whole lot easier.
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Retention Periods by Data Type: Examples & Best Practices
HR and Recruitment Data
This area sees a lot of personal data—from CVs and interview notes to payroll and performance records.
Recruitment: 6–12 months post-application
Employee files: Up to 7 years post-employment (depending on national law)
Tip: Ensure your HR team is trained on privacy basics—Responsum’s Awareness & Training module helps here.
Customer Data (Sales & Marketing)
Customer data is often the trickiest — especially if the original business purpose fades, but the data lingers on.
Inactive users: Consider deletion or anonymisation after 1–2 years of inactivity
Marketing consents: Retain proof of consent for as long as you’re using it — and document when it was withdrawn
Need to track consent effectively? Check out our Consent Management features.
Vendor and Supplier Records
Third-party data is often overlooked — but vendors can contain data on contact persons, security assessments, and signed agreements.
Supplier contracts: Retain during the relationship and a few years after (e.g., 5–7 years)
Vendor risk evaluations: Update annually and archive obsolete ones
Responsum’s Vendor Management makes this easier with centralised DPA tracking and risk scoring.
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Operationalising GDPR Retention Periods
Policies and spreadsheets can only get you so far. If you want to prove compliance and make retention policies part of your daily privacy practice, you need structured support.
Build Awareness Across Teams
Retention responsibilities don’t just sit with the DPO. HR, marketing, IT — they all play a role. A strong privacy culture means everyone knows what they’re collecting, why, and for how long.
Use microlearning, checklists, and reminders
Run periodic refresher sessions
Incorporate retention into onboarding flows
Our Awareness & Training module includes custom learning paths, quizzes, and campaign tracking.
Document, Prove, Repeat
Your retention policy should be living, not static.
Store it centrally and update it regularly
Log review cycles and deletion actions
Be ready to show evidence during audits or when authorities come knocking
With Responsum, you can centralise all your documentation — Policies & Procedures, Frameworks & Methodologies, and more — under one roof.
Key Takeaways: Get Retention Right Without Guesswork
GDPR retention periods aren’t about rigid rules — they’re about smart, purpose-driven data handling. The goal isn’t to keep data forever (or delete it too soon) but to manage it responsibly, with transparency and documentation.
With Responsum, you can:
Define retention periods based on processing purposes
Automate review and deletion workflows
Train staff and prove your practices to auditors and authorities
Because when it comes to data, less really can be more — especially when it comes to risk.
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